No Representation With Regard to Tax Treatment. The REIT and the Partnership make no representation to any Protected Partner or Partner Guarantors regarding the tax consequences to such partners of the Transaction or any other transactions contemplated herein including whether becoming a Partner Guarantor or entering into a DRO shall be respected for federal income tax purposes as causing such partner to be considered to “bear the economic risk of loss” with respect to indebtedness for purposes of Section 752 or Section 465 of the Code.
Appears in 5 contracts
Samples: Tax Protection Agreement, Tax Protection Agreement (DLC Realty Trust, Inc.), Tax Protection Agreement (DLC Realty Trust, Inc.)
